Filipinas Broadcasting Network v. Ago Medical and Educational Center

Doctrines: 

- The Court’s statement in Mambulao Lumber Co. v. PNB, 22 SCRA 359 (1968), that “a corporation may have a good reputation which, if besmirched, may also be a ground for the award of moral damages” is an obiter dictum. 

- Since Article 2219(7) of the Civil Code does not qualify whether the plaintiff is a natural or juridical person, a juridical person such as a corporation may validly complain for libel or any other form of defamation and claim for moral damages. 

- Where the broadcast is libelous per se, the law implies damages, in which case, evidence of an honest mistake or the want of character or reputation of the party libeled goes only in mitigation of damages.

Facts: Exposé is a radio documentary program hosted by Rima and Alegre. The program is aired every morning over DZRC-AM which is owned by Filipinas Broadcasting Network, Inc. (FBNI). Exposé is heard over Legazpi City, the Albay municipalities, and other Bicol areas. Rima and Alegre exposed various alleged complaints from students, teachers and parents against Ago Medical and Educational Center-Bicol Christian College of Medicine (AMEC) and its administrators. Claiming that the broadcasts were defamatory, AMEC and Angelita Ago, as Dean of AMEC’s College of Medicine, filed a complaint for damages against FBNI, Rima and Alegre on 27 February 1990. The trial court ruled that FBNI and Alegre are liable for libel. Both parties appealed to the CA. The Court affirmed the trial court’s decision but with modification, holding Rima solidarily liable with FBNI and Alegre.

Issue: Whether or not AMEC is entitled to moral damages.

Held: A juridical person is generally not entitled to moral damages because, unlike a natural person, it cannot experience physical suffering or such sentiments as wounded feelings, serious anxiety, mental anguish or moral shock. The Court of Appeals cites Mambulao Lumber Co. v. PNB, et al. to justify the award of moral damages. However, the Court’s statement in Mambulao that “a corporation may have a good reputation which, if besmirched, may also be a ground for the award of moral damages” is an obiter dictum.

AMEC’s claim for moral damages falls under item 7 of Article 2219 of the Civil Code. This provision expressly authorizes the recovery of moral damages in cases of libel, slander or any other form of defamation. Article 2219(7) does not qualify whether the plaintiff is a natural or juridical person. Therefore, a juridical person such as a corporation can validly complain for libel or any other form of defamation and claim for moral damages.

Where the broadcast is libelous per se, the law implies damages. In such a case, evidence of an honest mistake or the want of character or reputation of the party libeled goes only in mitigation of damages. Neither in such a case is the plaintiff required to introduce evidence of actual damages as a condition precedent to the recovery of some damages. In this case, the broadcasts are libelous per se. Thus, AMEC is entitled to moral damages. However, we find the award of P300,000 moral damages unreasonable. The record shows that even though the broadcasts were libelous per se, AMEC has not suffered any substantial or material damage to its reputation. Therefore, we reduce the award of moral damages from P300,000 to P150,000.